Dawn H. v. Commissioner, Social Security Administration

Summary

The United States District Court for the District of Oregon reviewed the Commissioner of Social Security's denial of disability insurance benefits and supplemental security income. The court held that the ALJ inadequately evaluated state agency psychological opinions concerning the need for a predictable work environment, reversed the decision, and remanded for further administrative proceedings, while upholding the ALJ's treatment of the consultative examiner's opinion regarding varicose veins.

Holdings

1. The ALJ erred by rejecting Drs. Barsukov and Tomak's opinions that Plaintiff was moderately limited in adapting to changes in the work setting and needed a predictable work environment with minimal deviation, because the reasons cited by the ALJ were not supported by substantial evidence and did not contradict those specific limitations.
2. The ALJ did not err in discounting Dr. Resendiz's opinion or in omitting limitations related to Plaintiff's varicose veins from the RFC.
3. Any error in the ALJ's step-two characterization of Plaintiff's varicose veins was harmless because the ALJ resolved step two in Plaintiff's favor and considered the alleged limitations at later steps.

Questions Presented

1. Whether the ALJ provided legally sufficient, substantial-evidence-supported reasons for rejecting the state-agency psychological opinions that Plaintiff needed a predictable work environment with minimal deviation.
2. Whether the ALJ erred by discounting the consultative examiner's opinion and failing to include limitations related to Plaintiff's varicose veins in the residual functional capacity.
3. Whether any error in the ALJ's step-two treatment of Plaintiff's varicose veins was harmless.

Disposition

reversed_and_remanded